Renewal, CE, and the Lapsed License
Marcus, RDH, has held an Arkansas dental hygienist license since 2019. His current license expires December 31. In October he realizes he has completed only 12 of the required continuing education hours for the renewal cycle. He plans to take two online courses in November (6 hours total) and one hands-on course in December (4 hours), which would bring him to 22 hours. He also moved in June and never updated his address with the Board. On January 4, he treats a patient in a dental office, believing his license is still valid because he submitted his renewal online on December 30 but the Board has not yet processed it. The office manager asks whether he can continue seeing patients while the renewal is pending.
1. Identify the compliance problems with Marcus's CE plan and address update, and explain the consequences.
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Marcus has several compliance issues. First, he must complete the required continuing education hours for the renewal cycle; Arkansas requires licensees to complete a specified number of CE hours per renewal period, and 12 hours by October with only 10 more planned may or may not satisfy the requirement depending on the cycle rules. He should verify the exact hour requirement and category distribution (including any required hands-on or jurisprudence hours) before the deadline. Second, failing to update his address with the Board is a violation of the licensure regulations and can result in missed renewal notices and disciplinary action. Third, submitting a renewal on December 30 does not extend the license beyond its expiration date. If the license expires December 31 and the renewal is not processed, Marcus is practicing on an expired license in January, which is unlicensed practice and a disciplinary ground.
2. Can Marcus treat patients on January 4 while his renewal is pending? What should he do?
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No. A pending renewal application does not authorize practice. Marcus may treat patients only if the Board has issued a valid license or a temporary authorization. He should immediately contact the Board to confirm the status of his renewal, refrain from patient care until the license is confirmed active, and document the lapse. Practicing on an expired or unprocessed license exposes him to discipline, including fines and possible license suspension, and exposes the employing dentist to liability for aiding unlicensed practice.
3. What should the office manager and supervising dentist do upon learning of the lapse?
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The office manager should verify licensure status through the Board's public license lookup before allowing any clinician to treat patients, and the supervising dentist should immediately remove Marcus from patient care until licensure is confirmed. The dentist should document the verification, notify the office's compliance officer or counsel, and ensure no billing occurs for services rendered during the lapse. The dentist should also review the office's credentialing process to prevent recurrence, such as requiring annual license verification for all staff.